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T.S. Ellis, the federal judge overseeing the case, said the recess could not be avoided and was due to unrelated matters.

While it's unclear what, if any, effect Judge Ellis' remarks and criticism may have on the outcome of the trial, the filing by Special Counsel Robert Mueller's team seems to indicate that the possibility is a concern, and one Mueller hopes to negate.

Ellis said it was a mistake to criticize Mueller's team in front of the jury for allowing a witness from the IRS to remain in the courtroom while other witnesses testified.

The delay came after special counsel Robert MuellerRobert Swan MuellerSasse: US should applaud choice of Mueller to lead Russian Federation probe MORE's team criticized Ellis in a court filing Friday, urging the judge to tell the jury to ignore one of his previous comments in order to prevent them from misunderstanding the gravity of testimony presented to them.

"Mueller deputy Andrew Weissmann and other attorneys on the team specifically noted how Ellis made negative comments this week about their focus on a bank loan Manafort applied for but did not receive", writes Fox.

According to reports from the courtroom, Ellis has repeatedly clashed with prosecutors during the trial and refused to allow them to present some evidence. Prosecutors said Ellis' crack "misrepresents the law" regarding bank conspiracy and "is likely to confuse the jury".

Later after bringing court back into session, he strongly reminded jurors that they weren't to discuss the tax evasion and bank fraud case with anyone.

Prosecutors have said that Calk pushed through the loans for Manafort because he wanted a job in the Trump administration.

Gates was indicted along with Manafort, but pleaded guilty and has been co-operating with Mueller's investigation. "You [the jury] [hav] ve got to put that aside".

That truce between the judge and prosecutors, though, did not last long. According to Talking Points Memo, Ellis called in the jury and instructed them to keep an open mind about the case.

But in their filing, prosecutors attached a transcript showing that in fact Ellis had approved the request a week before. "I'm not very patient, so don't try my patience", Ellis said.

On Wednesday, Ellis explained that he would not ask the defense to reveal as much information as he has demanded from the prosecution because "it's sort of like poker - you don't have to show your hand until you're called".

Gates has been the government's star witness in Manafort's financial fraud trial, testifying how, at the behest of his longtime boss, he helped hide millions of dollars in foreign income and submitted fake mortgage and tax documents. But I want you to remember don't do that again. It's unclear how Friday's delay will affect that.